Specialised Solutions for Fund Managers’ Compliance Management

We offer a comprehensive set of risk and compliance solutions tailored to a variety of investment fund managers' compliance obligations. We can help you comply with fund management regulations in a commercially oriented and goal-focused manner, providing a tailored approach to fund managers' compliance management with regard to your specific circumstances, including:

• Your investment products and solutions
• Your business goals
• Your business size
• Your technology and human resources
• Your risk appetite
• Your governance structure
• Your client demographics
• Your countries of operation, their applicable laws, and relevant fund managers' licensing requirements and regulations, including key aspects such as outsourced providers' monitoring, compliance training, risk management, audit, and assurance.
• Any related compliance obligations, including, but not limited to, fund managers' obligations under privacy laws, anti-money laundering and counter-terrorist financing (AML/CFT) laws, fair trading laws, and more.
• Investment fund managers' compliance assurance obligations, including internal control design and testing, implementation of compliance calendars, management plans, compliance assurance programs and other second and third-line compliance requirements.
• Specific operational compliance requirements for fund managers, including but not limited to:
  • Client due diligence and onboarding
  • Surveillance and monitoring
  • Recordkeeping
  • Conflict of interest management
  • Regulatory technology (RegTech) integration
  • Internal reporting
  • External reporting
  • Transaction execution
  • Regulatory Filings

 

What Jurisdictions Do Our Compliance Solutions Cover?

Our compliance solutions extend across major financial markets and cover fund management regulations and investment fund managers' licensing requirements compliance in the following jurisdictions:

• Australia: Where investment fund managers are typically structured as Managed Investment Schemes (MIS) and are regulated by the Australian Securities and Investments Commission (ASIC) under the Corporations Act 2001. MIS operators offering services to retail clients must hold an Australian Financial Services Licence (AFSL), while those dealing exclusively with wholesale clients may be exempt from certain provisions but generally still require an AFSL, albeit with fewer compliance obligations under the Corporations Act.
• New Zealand:  Where Managed Investment Schemes (MIS) are regulated by the Financial Markets Authority (FMA) under the Financial Markets Conduct Act 2013 (FMCA). Entities wishing to manage an MIS for retail investors must be licensed as a manager of a registered scheme under the FMCA, while those offering services solely to wholesale investors must register on the Financial Service Providers Register (FSPR) but are exempt from the FMCA licensing requirements.
• United Kingdom: Where investment fund managers are regulated by the Financial Conduct Authority (FCA) and can include structures like Unit Trusts, Open-Ended Investment Companies (OEICs), and Investment Trusts. Fund management companies dealing with retail clients need to be authorised by the FCA under the Financial Services and Markets Act 2000 (FSMA), whereas those serving only professional (wholesale) clients must still be authorised but may benefit from a lighter regulatory regime under the Alternative Investment Fund Managers Regulations 2013.
• European Union: Where investment fund managers are regulated under directives like the Undertakings for Collective Investment in Transferable Securities (UCITS) for retail funds and the Alternative Investment Fund Managers Directive (AIFMD) for alternative investment funds. Managers of funds aimed at retail investors must comply with UCITS, while those managing funds for professional (wholesale) investors need to comply with AIFMD, which includes registration or authorisation depending on the assets under management and provides certain exemptions for smaller managers.
• United States: Where investment funds, such as Mutual Funds and Exchange-Traded Funds (ETFs), are primarily regulated by the Securities and Exchange Commission (SEC) under the Investment Company Act of 1940. Fund managers dealing with retail investors must register their funds with the SEC, whereas managers of private funds offered exclusively to accredited or institutional investors (wholesale clients) can rely on exemptions such as Regulation D under the Securities Act of 1933 and may register with the SEC as an investment adviser under the Investment Advisers Act of 1940, unless exempt.
• Singapore: Where investment fund managers are regulated by the Monetary Authority of Singapore (MAS) under the Securities and Futures Act (SFA) and the Financial Advisers Act. Fund managers serving retail investors require a Capital Markets Services (CMS) Licence for fund management, while those serving only accredited or institutional investors (wholesale clients) may operate as a Registered Fund Management Company (RFMC), which must register with MAS but faces less stringent regulatory requirements compared to licensed entities.

Offshore Jurisdictions

• Cayman Islands: Where investment fund managers are regulated under the Mutual Funds Law and the Securities Investment Business Law (SIBL), supervised by the Cayman Islands Monetary Authority (CIMA). Fund managers dealing exclusively with wholesale clients, such as high-net-worth individuals and institutional investors, must register or obtain a license under the SIBL, while retail funds are generally not established due to the sophisticated nature of the market.
• Bermuda: Where investment fund managers must comply with the Investment Funds Act 2006, supervised by the Bermuda Monetary Authority (BMA). Managers offering funds to institutional and high-net-worth (wholesale) investors can benefit from exemptions and lighter regulatory requirements, while those targeting retail investors face more stringent regulations and must obtain the appropriate licenses under the Act.
• British Virgin Islands (BVI): Where investment funds are governed by the Securities and Investment Business Act (SIBA), under the oversight of the British Virgin Islands Financial Services Commission (BVI FSC). Fund managers serving professional (wholesale) investors can establish Professional or Private Funds with simpler registration processes, whereas retail funds (Public Funds) require full recognition and are subject to more extensive regulatory compliance under SIBA.
• Isle of Man: Where investment fund managers are regulated by the Collective Investment Schemes Act 2008, supervised by the Isle of Man Financial Services Authority (IOMFSA). Managers targeting wholesale investors can set up Specialized or Qualifying Funds with fewer regulatory requirements, while those offering funds to retail investors must establish Regulated Funds and comply with stricter oversight under the Act.
• Malta: Where investment fund managers are regulated under the Investment Services Act, overseen by the Malta Financial Services Authority (MFSA). Managers dealing with professional (wholesale) investors can establish Professional Investor Funds (PIFs) with more flexible regulatory obligations, whereas those serving retail investors need to set up UCITS or Retail Non-UCITS funds and adhere to comprehensive regulatory standards under the Act.

 

What Types of Fund Managers Do We Support?

Our investment fund managers' compliance solutions cover the following types of investment funds:

• Open-Ended Investment Companies (OEICs): Funds that issue shares and allow investors to buy or sell shares on demand.
• Unit Trusts: Funds structured as trusts, where investors buy units representing their share of the fund's assets.
• Investment Trusts: Closed-end funds that issue a fixed number of shares and are traded on stock exchanges.
• Hedge Funds: Private investment funds that engage in diverse and complex strategies to generate high returns.
• Mutual Funds: Investment vehicles that pool money from many investors to purchase securities.
• Exchange-Traded Funds (ETFs): Funds that track indices, sectors, or commodities and are traded on stock exchanges.
• Private Equity Funds: Funds that invest directly in private companies or engage in buyouts of public companies.
• Real Estate Investment Trusts (REITs): Companies that own, operate, or finance income-producing real estate.
• Venture Capital Funds: Funds that invest in early-stage, high-potential startups.
• Fund of Funds (FoFs): Funds that invest in a portfolio of other investment funds rather than directly in securities.
• Infrastructure Funds: Funds that invest in infrastructure projects like transportation, utilities, and renewable energy.
• Commodity Funds: Funds that invest in physical commodities or commodity-linked instruments.

For more wholesale investor-focused funds, we have dedicated compliance management pages for investment firms and fund managers.

 

Investment Fund Managers’ Compliance Advisory

Our focus areas include:

• Detailed Compliance Advice: Covering fund managers' compliance management issues across the first, second, and third lines, as well as matters related to effective compliance with investment reporting obligations and fund managers' licensing requirements.
• Banking Relationships Advice: On risk and compliance issues related to managing and expanding relationships with banks, liquidity providers, and other financial institutions to help you meet their risk appetite requirements, anti-money laundering and counter-terrorist financing requirements, fraud prevention and recall volume expectations, and other compliance-related and operational standards.
• Operational AML Advice: Advising support, onboarding, KYC, operating and other teams on the day-to-day onboarding and support queue management, effective AML/CFT resource allocations, and operational improvements, helping you maintain the overall customer experience and efficiency while remaining compliant with the fund managers' AML/CFT requirements.
• Operational Compliance Advice: Advising compliance, management, technology, and support teams on the day-to-day compliance with fund management regulations, focusing on internal processes and critical internal controls for effective fund managers' compliance management.
• Risk Management Advice: Covering risk rating and methodologies, risk assessments, management, and mitigation for various risk types faced by fund managers, including regulatory, ML/TF, fraud, data protection, and operational risks. We help you safeguard against potential compliance breaches and comply with risk management obligations under fund managers' licensing requirements and other applicable laws and regulations.
• Compliance Framework Advice: To help you create or enhance your compliance management framework, identify gaps and areas of improvement, meet the investment fund managers' compliance obligations effectively, improve internal governance and reporting, and optimise them for market expansion and growth.
• Fund Managers' Licensing Advice: We can guide you through the licensing process, help you apply regulations to your specific circumstances and business environment, and meet fund managers' licensing requirements to become licensed or maintain it.
• Peer Benchmarking and Best Practices: We can help you benchmark your compliance practices against peers and applicable regulatory compliance guidance, identify areas for improvement and adopt best practices for enhanced compliance.
• Government Agencies Liaison Advice: We provide strategic guidance to senior management and compliance teams on maintaining and managing relationships with external bodies, including regulators, AML/CTF supervisors and law enforcement agencies, focusing on long-term compliance strategies and proactive engagement.
• Specific Investment Fund Managers' Compliance Issues: We can help you resolve specific risk or compliance issues related to fund management regulations and compliance obligations, including but not limited to external audits and reviews, reporting, oversight, difficult clients or transactions, expansion challenges, compliance management issues, process optimisation, regulatory challenges you may encounter and more.
• Further information: You can visit our Regulatory Compliance Consulting Solutions page for a comprehensive list of advisory services we offer to fund managers and other licensed financial institutions, financial services providers, and regulated businesses.

 

Reporting and Regulatory Liaison Solutions for Fund Managers’ Compliance

• Regulator Liaison Management: Providing operational guidance to senior management and compliance teams on managing relationships with regulators, AML/CFT supervisors, police bodies, privacy commissioners, and other government entities. This includes handling requests for information, responding to ad-hoc regulatory inquiries, managing findings from audits and investigations, managing compliance with reporting obligations for fund managers and more.
• Board and Committee Reporting: Facilitating structured reporting workflows for various committees and board delegates, including risk, compliance, and audit committees, focusing on your current compliance status, deviations from your risk appetite, changes in risk ratings and any operational compliance updates to ensure that governance structures are well-informed and aligned with compliance management practices.
• Compliance Performance Metrics: Developing and presenting comprehensive compliance performance metrics to the board or relevant committees, offering insights into your compliance effectiveness and identifying points for improvement in key compliance areas, including compliance training, fraud prevention, compliance monitoring, risk rating and assessment, controls effectiveness, adherence to your compliance calendar, regulatory technology (RegTech) performance, and more.
• Internal Audit Reporting: We can help you increase the effectiveness of the internal audit to make its findings reflect your actual performance against the investment fund managers' compliance obligations. This includes developing tailored methodologies for the auditors, preparing the necessary audit evidence and reviewing audit results. The goal is to ensure that audit procedures and outcomes directly contribute to maintaining and enhancing your compliance status and internal controls' effectiveness.
• AML/CFT Reporting Compliance:  We help with the implementation of effective AML/CFT reporting processes, aligning with specific anti-money laundering regulations for internal oversight and prompt escalation of critical AML issues within your business to help the management receive a clear overview of your AML/CFT compliance status.
• Transactional Reporting: Implementing effective transactional reporting procedures to help with fund managers' compliance management of reporting obligations under various laws and regulations, including submitting SAR, SMR, STR, PTR, TTR, specific reportable matters under the fund managers' licensing requirements and other externally reportable transactions and activities.
• Internal Quality Assurance Reporting: While second-line control testing is crucial for complying with fund management regulations, including fund managers' licensing requirements, first-line quality assurance results are equally important for effective risk and compliance management. We help organise effective reporting lines, tailor reporting content to your specific circumstances, products, and team size, and establish a structured approach to responding to reporting outcomes.

 

 

Comprehensive Compliance Management Solution for Fund Managers

Our compliance management services include, but are not limited to, the following:

• Fund Managers' Compliance Management Leadership: We act as your Compliance Leads and Compliance Managers, fully managing compliance obligations under the applicable fund managers' licensing requirements, laws, regulations, industry codes, and regulatory guidance.
• Second-Line Compliance Management: We offer a full range of second-line compliance assurance solutions, including internal controls testing for operational, compliance, marketing, legal and other risks, as well as managing issue closure control testing and more.
• Supporting the Board in Strategic Compliance Management: Advising on the necessary compliance resourcing, budget, tools, role structuring, and compliance functions' structure to support your specific business objectives within your risk appetite and risk management framework.
• Compliance Project Management: Effectively coordinating between senior management, committees, legal advisers, risk and compliance functions, outsourced providers, and different departments, including product development, technology, customer support, operations, assurance, marketing, and others, to help you successfully implement compliance projects across the business.
• Customised Governance Solutions: Tailoring governance frameworks and mechanisms to fit your specific governance structure and effectively comply with fund management regulations and other applicable obligations. Whether your business is locally oriented, a start-up, undergoing expansion, part of a multinational group, has a listed parent company or is undergoing restructuring, we tailor the oversight of fund managers' compliance management to your business case.
• Stakeholder Management and Reporting: Reporting to the board, committees, shareholders, regulators and other stakeholders. Providing management and the board with comprehensive compliance reports that cover your compliance with investment fund managers' compliance obligations, regulatory development summary, compliance-related data and statistics, internal controls testing outcomes and more. Also covering the status of your specific compliance-related projects and compliance goals, relevant compliance KPIs, and more.
• Compliance Calendar Implementation: We design and implement compliance management programs and calendars, covering such areas of investment fund managers' compliance obligations as policy and key document reviews, control testing, risk assessment and reviews, vendor reviewers, user system access reviews, assurance activities and more.
• Managing Customer Onboarding and Due Diligence: Implementing commercially oriented and compliant processes for KYC information collecting, Know Your Business (KYB), ML/TF risk assessment, Pep and Sanctions screening, CDD and EDD, especially for higher ML/TF risk clients, to help you comply with AML/CFT compliance obligations for fund managers.
• AML Transaction Monitoring and Reporting: Developing and implementing a set of business-specific ML/TF alerts and red flags to detect and report suspicious transactions to comply with the fund managers' AML requirements without making AML/CFT compliance a hindrance to business.
• Information Requests and AML/KYC Data Sharing: Handling information requests from law enforcement agencies, AML/CTF supervisors, and other relevant AML/CTF designated entities, such as your banking partners and other essential service providers (liquidity providers, finance providers, etc.), ensuring that you are fully supported in all AML/CTF compliance-related communications.
• Business Expansion Support: Providing support for your business expansion objectives, recognising and assessing new risks, developing and implementing controls and mitigations for them, as well as addressing new compliance obligations and putting in place practical tools and systems to manage them.
• Fund Managers' Operational Compliance: Including but not limited to:
  • On-the-Ground Compliance: Conducting compliance management meetings, organising routine and ad hoc compliance reporting, overseeing mitigations and controls testing, leading adjustments and enhancements to your internal controls and protocols when required.
  • Compliance Process and Operations Building: Developing effective and compliant procedures and processes to implement your policies, support your operations across different teams and mitigate operational, regulatory and other risks.
  • Outsourced Provider Performance Monitoring: Setting up initial due diligence and ongoing review frameworks for your outsourced providers to help you meet the required service standards for outsourcing under various investment fund managers' compliance obligations, including fund managers' licensing requirements.
  • Incident Management and Reporting: We can help you set up effective processes for incident reporting, escalations, and management at different levels of your business.

 

Fund Managers’ Compliance Assurance 

Our services include:

• Compliance Assurance Programs:  We can design and implement your compliance assurance program to maintain enhanced oversight of your compliance with both fund managers' regulations and your internal compliance and risk appetite thresholds.
• Organisation-Wide Risk Assessments: Helping you focus on the specific risks faced by your business, considering its size, products, client types, jurisdictions of operation, delivery channels, financial institutions you interact with, available technology, and other tools. This includes assessing available mitigations, controls, their effectiveness, residual risk ratings, and the plan to move forward.
• Internal Controls Design: We can develop internal controls for various risk types, including regulatory, fraud, operational, strategic, financial, and other risks. Please visit our Internal Controls Design page for more information. 
• Assurance Testing: We conduct assurance testing to verify that the business complies with its policies, procedures, and investment fund managers' compliance obligations, including fund managers' licensing requirements. We also assess whether your internal controls effectively mitigate existing risks, including those required to be monitored under the applicable fund management regulations. This process includes a compliance controls testing report and, if necessary, a gap analysis.
• Compliance Quality Assurance: We go beyond merely meeting regulatory requirements. We focus on evaluating and enhancing your risk and compliance management processes to ensure they align with your current and future goals, business model, your risk analysis, your current client inflow, and more. We also suggest which compliance processes you can use to meet your goals. Here is an example of this service in the AML/CFT area.
• Assurance Reporting: Compiling testing findings and issuing comprehensive compliance assurance reports, which include:

• Identification of any deficiencies or control weaknesses, with clear explanations and potential root cause analysis.
• Recommendations for corrective actions to address identified issues and enhance compliance effectiveness.
• Evaluation of the overall effectiveness of your internal controls and regulatory compliance monitoring program against your desired assurance level.

• Regulatory Inspection Readiness: We can help your business prepare for external audits and regulatory inspections, reducing the risk of adverse findings related to investment fund managers' compliance obligations. This includes conducting mock inspections to identify gaps, reviewing documentation and record-keeping practices to ensure all relevant materials are well-organised and readily accessible, and training staff on their roles in the inspection process. We assist in identifying any missing information and weak points, provide interview preparation, and more to ensure readiness for auditor or regulator review.
• Further information: You can visit our Compliance Assurance Solutions page for more information on our third-line compliance assurance review solutions.

 

Compliance Remediation Solutions

Our focus areas include:

• Compliance Remediation Advice: Assisting fund managers in effectively addressing and rectifying compliance issues, from minor breaches to significant regulatory challenges, including warnings and action plans.
• Remediation Plan Development: Following the independent review, we assist in analysing the findings to identify necessary remedial actions. We then support fund managers in devising a detailed plan outlining these actions for submission to your regulator or an AML/CFT supervisor, ensuring the plan is both actionable and compliant with regulatory expectations.
• Remediation Plan Commitment: We help fund managers complete their remediation plans and prevent non-compliance recurrence.
• Executive Attestation Support: Our services include assisting senior executives in preparing the required attestations to your regulator. This involves confirming that all necessary remedial actions have been undertaken and adequate compliance measures are in place, supported by comprehensive documentation and evidence. This option covers assistance with the removal of any licensing restrictions.
• Further Information: For more information, you can visit our Compliance Remediation Solutions page.

 

Internal Controls Testing and Fund Managers’ Compliance Management

When it comes to reality versus a nice policy or procedure with nothing else to show for it, it’s often a case where a policy says A, but reality says B. One might ask, why didn’t we test our internal controls before? Or, why didn’t we do it properly? There’s nothing worse than faking compliance instead of actually doing it.

Our second line of compliance defence solutions covers the development, testing, and enhancement of a wide range of controls to ensure compliance with various laws and regulations governing fund managers' compliance obligations.

We go beyond merely quoting fund management regulations or a selection of licensing requirements, then adding Excel sheets painted in different colours as a supposed source of truth with nothing to show for it.

• We test them.
• We link them to your risk appetite and core risk management documentation.
• We provide relevant suggestions and analysis tailored to your business.

Some of our focus areas for testing the investment fund compliance requirements include:

 

Regulatory Compliance and Licensing Controls

• Compliance Management: Fund managers should establish robust systems for investment fund compliance management, including conflict of interest management.
• Liquidity Management: Fund management companies should ensure adequate liquidity to promptly meet financial obligations. Licensed fund managers should implement comprehensive risk management standards that cover various risk types, ensuring robust risk frameworks are established.
• Capital Adequacy: Fund managers should maintain a certain level of tangible financial resources, including net assets and/or net tangible assets (NTA), to absorb potential losses, following the rules on where and how the NTA should be maintained.
• Financial Auditing: Fund management businesses should engage qualified auditors who should conduct regular financial audits to verify the accuracy of investment fund financial statements and ensure regulatory compliance.
• Regulated Counterparty Engagement: Investment management businesses should comply with restrictions on engaging in transactions with financial service providers that are not regulated or authorised by a competent authority.
• Cross-Border Application of Regulations: Fund management companies should ensure compliance with specific guidelines and rules regulating the cross-border application of national investment fund licensing requirements to overseas funds offering services to their retail clients in their jurisdictions.
• Investment Strategy Compliance: Fund managers should ensure adherence to their stated investment strategies and restrictions as disclosed in fund prospectuses or offering documents, aligning with regulatory requirements and investor expectations.
• Anti-Money Laundering/Countering Financing of Terrorism (AML/CFT) Controls: Fund managers should implement a range of AML/CFT controls, covering obligations such as customer due diligence during onboarding, transaction monitoring, ongoing due diligence, reporting of certain transactions, staff vetting, and more.
• Tax Compliance: Investment fund managers should ensure adherence to relevant tax regulations in jurisdictions where the fund operates.
• FATCA and CRS Controls: Fund management companies should comply with FATCA and CRS controls, depending on the fund's domicile, investor residency, and investment activities.

 

Operational Oversight Controls

• Outsourcing Oversight: Fund managers should maintain control and oversight over outsourced functions, such as fund administration, custody, and investment management, to ensure they do not compromise regulatory obligations or client protection.
• Risk Management: Fund management businesses should establish comprehensive risk frameworks and procedures to identify, assess, and manage investment, operational, and compliance risks in line with the fund's investment strategy.
• Governance Arrangements: Investment managers’ entities should establish effective governance structures to oversee operations and ensure responsible management and decision-making.
• Senior Management Accountability: Fund managers’ firms should assign specific responsibilities to senior managers to ensure accountability for fund performance and regulatory compliance.
• Operational Resilience: Fund management companies should ensure the resilience of critical business services, including trading, valuation, and investor communications, with plans to maintain continuity in the face of disruptions.
• Technology Risk Management: Investment fund managers should manage the risks associated with investment and trading platforms, cybersecurity, data privacy, and data protection.
• Valuation Practices: Fund managers should implement controls for valuing illiquid or hard-to-value assets according to regulatory standards and best practices.
• Automated Trading Supervision: Fund management businesses should supervise automated trading systems (such as algorithms) used by clients to ensure they operate within set parameters and comply with regulatory requirements. Monitoring automated trades helps prevent market abuse and ensures adherence to trading rules.

 

Market Integrity and Transparency Controls

• Market Conduct Standards: Fund managers should ensure market conduct is fair, transparent, and free from abuse, including manipulation or insider trading.
• Fair Dealing Principles: Fund managers should adhere to principles ensuring fair treatment of all fund investors, with clear communication and transparent dealings.
• Conduct and Disclosure Standards: Fund managers should maintain high standards of conduct and ensure that disclosures to investors about the fund's investment objectives, risks, and performance are clear, accurate, and effective.
• Service Provision Standards: Fund management companies should provide fund services efficiently, honestly, and fairly.
• Product Governance: Fund management businesses should have adequate arrangements for fund design, approval, and review, ensuring they meet regulatory requirements and investor needs.
• Investor Communication: Fund managers should establish standards for regular and ad hoc communication with investors regarding performance, market events, and changes in management or strategy.
• Client Asset Protection: Fund managers should ensure investor assets are protected and segregated from fund assets, with clear rules on their use and handling.
• Dispute Resolution: Investment managers’ entities should have proper mechanisms for dispute resolution and investor compensation, especially for retail investors.
• Trade Reporting and Transparency: Fund managers should ensure that all significant trades are reported accurately and in a timely manner to relevant regulatory bodies. Transparency in transaction reporting is essential for maintaining market integrity.
• Client Communication and Disclosures: Fund managers should ensure clear and timely communication with clients regarding transaction confirmations, changes in account status, and any significant events that might affect trading conditions. Transparency in communication helps build trust and ensures clients are well-informed.
• Risk Warnings and Disclosures: Fund managers should provide clients with clear risk warnings about the potential risks of trading, including the use of leverage and the possibility of losing more than the initial investment. Proper risk disclosure helps clients make informed trading decisions.

 

Resource Management Controls

• Resource Adequacy: Fund management companies should maintain adequate financial, technological, and human resources for effective fund management, compliance, and investor servicing.
• Professional Competence: Fund managers should ensure key personnel possess the necessary competence, knowledge, and skills.
• Advisor and Representative Competence: Fund management businesses should ensure staff providing investment advice or investor services are adequately trained and qualified.

 

Reporting Controls

• Regulatory Reporting: Fund managers should conduct regular reporting on fund activities, compliance, and risk management to regulatory authorities. This includes periodic submissions such as financial statements, risk reports, and compliance updates to meet regulatory requirements.
• Investor Reporting: Investment fund managers should provide regular and transparent updates to investors on fund performance, portfolio holdings, and any significant changes in the investment strategy or management. This ensures that investors are well-informed about the status and performance of their investments.
• Portfolio Transaction Reporting: Fund management companies should report significant transactions and changes in the fund's portfolio to investors as required. This helps maintain transparency and accountability within the fund.
• Record-Keeping: Fund managers should keep accurate records of all business transactions, financial matters, and investor communications to ensure transparency and accountability. This includes maintaining detailed records of investor transactions, fund performance, and operational activities in compliance with regulations.
• Performance Reporting Standards: Fund managers should set clear guidelines for performance reporting, including benchmarks, calculation methodologies, and fee/expense disclosures.
• Compliance Reporting: Fund managers should conduct regular reporting to demonstrate adherence to regulatory requirements, internal policies, and ethical standards. This includes compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations, as well as other applicable laws.

 

Product and Service Management Controls

• Product Suitability: Fund managers should ensure that products offered are appropriate for clients, considering their knowledge, experience, and financial situation.
• Product Lifecycle Oversight: Fund management businesses should have procedures in place for product lifecycle management, from design to distribution, ensuring client suitability and market integrity.
• Execution Quality: Fund managers should take sufficient steps to ensure the best possible result for client orders, considering various execution factors.
• Data Protection and Privacy: Fund managers should adhere to robust data protection standards that align with national data protection laws for financial institutions.
• Compliance with ESG Criteria: Investment fund managers may have to ensure that investments align with these criteria for ESG-focused funds and that ESG disclosures meet regulatory standards.

 

Transactional Controls for Investment Funds

• Conflict of Interest in Transactions: Fund managers should identify and manage conflicts of interest, particularly in pricing, order execution, and proprietary trading. Implementing clear policies and procedures helps maintain transparency and protect client interests.
• Periodic Review and Reconciliation: Fund managers should conduct regular reviews of trading activities, account balances, and client exposures to ensure accuracy, compliance with trading conditions, and effective risk management. Periodic reconciliation helps identify discrepancies and maintain financial integrity.
• Side Pocket Arrangements: fund management Companies should establish controls for transparent and fair use of side pockets for illiquid investments, in line with regulations and investor agreements.
• Transaction Cost Management: Fund managers should monitor and control transaction costs to ensure they align with the fund's objectives.
• Trade Order Management: Fund managers should ensure accurate and compliant execution of trades in the best interest of the fund and its investors. (Relevant for OEICs, Unit Trusts, Mutual Funds, ETFs, Hedge Funds, Private Equity Funds, REITs, Venture Capital Funds, Fund of Funds, Infrastructure Funds, and Commodity Funds).
• AML/CTF Transaction Monitoring: Fund managers should monitor transactions for large, complex, and unusual patterns, perform enhanced due diligence, and report suspicious activities to authorities. Reporting certain international transactions as required.

 

Fund Managers’ Licensing and Registration Solutions

• Financial Licensing Application Support: We provide comprehensive support for a wide range of fund managers' licensing applications, including:

• AFSL Application for Managed Investment Schemes in Australia: We assist with AFSL applications for MIS operators, ensuring compliance with ASIC regulations. For more information on how we can help you comply with the fund managers' licensing requirements in Australia, you can visit our AFSL page for MIS Managers.
• Fund Managers' Licensing in New Zealand: We support the licensing process for MIS managers and DIMS managers with the FMA, facilitating compliance with the FMCA. For more information on how we can help you comply with the fund managers' licensing requirements in New Zealand, you can visit our MIS Licence or our DIMS Licence pages.
• FCA Authorisation for Fund Management Companies in the UK: We guide fund management companies through the FCA authorisation process for operating collective investment schemes. For more information on how we can help you comply with the UK fund managers' authorisation, you can visit our FCA Authorisation page for Consumer Investment Firms.
• SEC Registration for Mutual Funds and ETFs in the US: We provide consultancy for SEC registration of fund managers in line with the Investment Company Act.
• UCITS and AIFMD Compliance in the EU: We advise on compliance with UCITS and AIFMD for funds and managers operating within the EU.
• CMS Licence Application for Fund Managers in Singapore: We assist with the CMS Licence application process for fund management activities under MAS regulations. For more information on how we can help you comply with the fund managers' licensing requirements in Singapore, you can visit our CMS Licence page.
• Mutual Funds Law and SIBL Compliance in the Cayman Islands: We offer comprehensive support for obtaining licences under the Mutual Funds Law and the Securities Investment Business Law (SIBL), ensuring compliance with CIMA's regulations.
• Investment Funds Act Compliance in Bermuda: We provide assistance with the licensing process under the Investment Funds Act 2006, ensuring alignment with BMA's regulatory framework for high-net-worth and institutional investors.
• SIBA Licensing for Funds in the British Virgin Islands (BVI): We guide fund managers through the licensing requirements of the Securities and Investment Business Act (SIBA), ensuring compliance with BVI FSC regulations.
• Collective Investment Schemes Act Licensing in the Isle of Man: We support the licensing process under the Collective Investment Schemes Act 2008, ensuring compliance with IOMFSA regulations for investment funds.
• CSSF Authorisation for Funds in Luxembourg: We assist with the application process under the Law of 17 December 2010, ensuring compliance with the Commission de Surveillance du Secteur Financier (CSSF) for both UCITS and alternative investment funds.
• Investment Services Act Licensing in Malta: We provide comprehensive support for obtaining licences under the Investment Services Act, ensuring compliance with Malta Financial Services Authority (MFSA) regulations for a variety of fund structures.

• International Governance Alignment: We provide strategic advice on aligning governance models for fund managers operating across multiple jurisdictions to meet diverse regulatory expectations while maintaining operational efficiency and regulatory compliance.
• Further information on Fund Management Regulations: For more information on how we can help you comply with the fund managers' licensing requirements in other jurisdictions, you can visit our Fund Managers' LIcence page.

 

Policies and Procedures for Fund Managers’ Compliance Management

• Compliance Policies and Core Documents: We develop, enhance, and implement a set of core policies, manuals, frameworks, and procedures for effective fund managers' compliance management.
• Effective Procedures for Investment Funds' Compliance Management: We draft and enhance a detailed set of procedures and protocols to meet the distinct needs of your business, focusing on efficient compliance, your business goals, and applicable fund managers' compliance requirements.
• Examples: These policies and procedures include, but are not limited to:

 

Operational Compliance

• Compliance Management Frameworks
• Compliance Monitoring Programs
• Compliance Calendars and Checklists
• Complaints Handling and Dispute Resolution Policies
• Compliance Training Manuals and Programs, as part of our regulatory compliance training solutions
• Obligation Registers
• Margin Account Negative Balance Write-Off Procedures
• Incident Reporting Policies and Procedures
• Outsourcing Policies and Vendor Risk Management policies as part of our outsourced provider's compliance management solutions
• New Client Account Opening Policies and Procedures, as part of our customer onboarding solutions
• Investment Strategy Compliance Policies
• Liquidity Management Policies

 

Governance and Oversight

• Board Charters, Risk, Audit and Compliance Committee Charters, as part of our corporate governance solutions
• Codes of Conduct
• Delegations Registers
• HR Manuals and Policies
• ESG Compliance Policies
• Conflict of Interest Policies

 

Risk Management

• Risk Management Frameworks as part of our risk management solutions
• Risk Assessment Guidelines and Methodologies
• Internal Control Testing Methodologies
• Risk Registers and specialised risk registers like Health and Safety Risk Registers
• Cybersecurity Risk Management Policies
• Valuation Policies
• ESG Investment Policies

 

Audit and Assurance

• Compliance Assurance Programs as part of our compliance assurance solutions
• Internal Audit Policies and Programs as part of our internal control testing solutions
• Regulatory Reporting Procedures

 

Client and Market Conduct

• Client Communication Policies
• Marketing and Advertising Policies
• Staff Dealing and Insider Trading Policies

 

AML/CFT and Financial Crime Compliance

• AML/CFT Compliance Programs
• AML/CFT Risk Assessment
• Whistleblowing Policies
• Sanctions Compliance policies and procedures
• Fraud Prevention Protocols and Controls as part of our fraud prevention solutions
• ABC Policies

 

Privacy and Data Management

• Client Data Protection Policies
• Record-keeping Policies and Procedures and/or Data Governance Policies as part of our record-keeping compliance solution
• External Privacy Policies
• Internal Data Protection Compliance Programs

 

 

Compliance Training and Capacity Building

We focus on practical compliance and the application of training to real-world compliance scenarios and challenges that fund managers generally face. Our services include:

• Customised Compliance Training Solutions:  Specialised compliance training sessions for various teams, including management, compliance, operations, sales, and customer relations, focusing on fund management regulations, applying fund managers' compliance management practices to your circumstances, risk awareness, and more.
• Up-to-date Regulatory Compliance Updates:  Keeping compliance officers, managers, CROs, COOs, and other Risk and Compliance team members informed of changes in fund managers' licensing requirements and regulations, AML/CFT updates, and changes in regulatory guidance.
• Data Analysis for Effective Compliance Monitoring: Covering training on compliance-related, data-based analysis and its results, including risk rating, internal control adjustments, resource and focus reallocation, and more.
• Workshops on Emerging AML Trends and Red Flags: Updating on new AML trends, red flags, typologies, and AML/CFT requirements for fund managers. For more information, please visit our AML/CFT Training Solutions page.
• Practical Workshops: Interactive workshops focused on effective and goal-oriented Investment fund managers' compliance, capacity planning, and resource allocation, covering:

• Fund management regulations
• Internal and external compliance reporting
• Effective governance over risk and compliance functions
• Organisation-wide risk assessment, risk rating methodologies and the development, management, and testing of corresponding internal controls, including controls testing methodologies and practical techniques.
• Investment Fund Managers' compliance reality, including outsourced provider monitoring, UAV management, incident management, product suitability assessments, advertising and marketing compliance, improvements in the client onboarding journey, transaction monitoring processes, and more.

• Further information: You can visit our Compliance Training Solutions page for more information on the compliance training services we offer to licensed financial institutions and financial service providers.

 

Fund Managers and AML/CTF Compliance

We offer a complete set of solutions covering fund managers' anti-money laundering (AML), financial crime and counter-terrorism financing (CTF) compliance. Our solutions include:

• Customer due diligence, screening, and customer onboarding solutions
• Development of transaction monitoring frameworks tailored to fund managers' specific ML/TF red flags and your business specifications
• AML advisory covering fund managers' compliance issues and challenges
• Drafting, testing, and updating AML policies and procedures
• AML training and capacity building
• Managed AML compliance solutions for fund managers
• Internal and statutory AML/CFT audit solutions for fund managers
• Financial crime prevention framework development focusing on common fraud risks faced by fund managers.
• For more information, please visit our specialised AML Compliance Solutions page for Wealth Managers

 

Investment Fund Managers’ Compliance Technology Integration

Our services cover compliance aspects concerning the integration of technology for risk and compliance e-management, transactional reporting (where applicable), usage of AI, technology outsourcing, and compliance aspects of third-party risk management for fund managers, including:

• Needs Assessment
• Compliance Technology Selection: Based on your budget, products, available operational and technical resources, and the applicable investment fund managers' compliance obligations
• Implementation assistance across the organisation
• Streamlining operational workflows: For routine compliance tasks like data collection, reporting, and risk assessments
• AML/CFT Compliance Technology: Covering customer digital onboarding, E-KYC, PEP and sanctions screening, transaction monitoring, etc.
• Integration of investment fund managers' compliance obligations into an effective CRM system
• Record-Keeping Obligations: Helping you choose and integrate the necessary tools to comply with the record-keeping requirements under various laws and fund management regulations

 

Data Management and Information Privacy Solutions

• Data Governance and Compliance:  Assisting fund managers in establishing robust data governance procedures, programs, and protocols that align data collection, storage, and usage practices with relevant data privacy regulations, such as GDPR, CCPA, and other applicable laws. These measures safeguard sensitive client and business information from unauthorised access, breaches, and misuse.
• Privacy Policy Compliance Monitoring: Helping you implement privacy policies that reflect the latest data protection legislation, supported by continuous compliance monitoring tools to maintain the highest data privacy standards.
• Record Maintenance Protocols:  We assist in developing and implementing effective procedures for maintaining necessary records, covering investment fund managers' compliance with applicable regulatory reporting standards and reporting requirements.
• Record Availability and Inspection Readiness:  Fund management regulations often require records to be readily available for inspection by regulators, AML/CFT supervisors, tax agencies, and other relevant authorities. This extends to information kept by your outsourced service providers. We help you organise your record-keeping processes to meet these needs.

 

ISO Standards and Investment Fund Managers’ Compliance

• Cross-Reference Mapping: Integrating ISO standards such as ISO 27001, ISO 9001, and ISO 22301 into an existing compliance framework and linking specific sections of ISO standards to corresponding procedures in your internal policies and procedures.
• Pre-Audit Preparation: Coordinating ISO controls testing across different parts of the business.
• Leading evidence collection across the different departments to cover relevant compliance areas such as planning, governance, organisational controls, operational controls, technological controls, and physical controls through structured workflows.
• Digital Compliance Repository: Helping you utilise a centralised digital repository for storing all compliance-related documents and evidence, making it easily accessible for audit purposes and compliance verification.
• ISO Audit Liaison:  Acting as a liaison between your team and the auditors, coordinating information requests, and ensuring all the necessary documentation is readily available.
• Post-Audit Remediation Management: We can lead the implementation of your remediation plan and support corrective actions to address all audit findings effectively.

 

Regulatory Change Management Solutions

Empower Your Business with Proactive Regulatory Change Management:

• Stay Ahead of the Curve:  We actively monitor regulatory updates from global financial authorities like MAS, ASIC, FMA, FCA, SEC, and other regulators for investment fund managers' compliance changes and updates to evaluate the implications of regulatory changes.
• Impact Assessment and Mitigation Strategies: We analyse the potential impact of regulatory changes on fund managers' compliance management frameworks and operational processes. We then collaborate with you to develop effective mitigation strategies that support continued compliance and minimise disruption.
• Seamless Implementation and Change Management:  We guide fund managers through necessary process adjustments, update internal policies and procedures, facilitate a smooth transition through regulatory changes, and assist with effective communication with impacted stakeholders.